Internal investigation on suspicion of bribery—checklist
Produced in partnership with Quinton Newcomb of Fulcrum Chambers
Internal investigation on suspicion of bribery—checklist

The following Corporate Crime practice note produced in partnership with Quinton Newcomb of Fulcrum Chambers provides comprehensive and up to date legal information covering:

  • Initial Considerations
  • Initiating an investigation
  • Conduct of the investigation
  • Dealing with the regulator
  • Dealing with other stakeholders

The following questions and issues should be at the forefront of a lawyer’s mind when advising in relation to an internal investigation on suspicion of bribery. This Checklist should be read in conjunction with Practice Notes: The Bribery Act 2010—an introductory guide, Failing to prevent bribery and Self-reporting corporate offences.

Initial Considerations


  1. Has the company appointed an officer of sufficient seniority responsible for anti-bribery and corruption?

  2. Does the Board, or an appropriately constituted sub-committee of the Board, have oversight of the work of the anti-bribery officer and any investigation arising out of such reports?

Internal reporting/whistleblowing

  1. Does your company have a defined whistleblowing strategy?

  2. Is it well-known and enforced throughout the company?

  3. Has your company got clear reporting channels for reporting suspected bribery?

  4. Does your company provide a confidential whistleblowing help line?

  5. If a report of suspected bribery is received through a help line or through any other channel, does the company have an internal investigation procedure to implement?

  6. Does procedure include provision for anyone connected to the allegation being compelled to retain and secures all documents, correspondence, emails, invoices or receipts so that they can be collected and examined (the company should have 'document retention notices' prepared for such instances)?

Initiating an investigation

  1. The anti-bribery officer should be informed of any report or suspicion that

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